A. General
We, PROSHNO UTTOR, incorporated under the Bangladeshi Companies Act (Act XVIII), of 1994
(hereinafter referred to as "Company" or "PROSHNO
UTTOR"), is committed to
safeguarding your privacy in relation to the protection of your personal
information. The Services are governed by this Policy, and any other rules,
policies or guidelines published on the Platform as applicable to you.
Please read this Policy carefully prior to accessing our Platform and
using the Services. By accessing and using the Platform, providing your
Personal Information (defined below), or by otherwise signalling your agreement
when the option is presented to you, you consent to the collection, use,
disclosure, sharing and storing of information described in this Policy, Terms
of Service and any other rules, policies or guidelines published on the
Platform as applicable to you (collectively referred to as the "Platform
Terms"), and PROSHNO UTTOR disclaims all the liabilities arising therefrom. If you have
inadvertently submitted any Personal Information to PROSHNO
UTTOR prior to reading this
Policy statements set out herein, or you do not agree with the way your
Personal Information is collected, stored, or used, then you may access, modify
and/or delete your Personal Information in accordance with this Policy.
If any information you have provided or uploaded on the Platform violates
the Platform Terms, PROSHNO UTTOR may be required to delete such information upon informing you of
the same and revoke your access to the Platform if required. If you have any
questions about this Policy, please contact us proshno@proshnouttor.com.bd.
B. Controllers
PROSHNO UTTOR is the controller of Personal
Information that it collects and processes in connection with the use of the
Platform and the provision of the Services on the Platform. The kind of
Personal Information we collect in connection with such use is detailed below.
C. Personal Information
“Personal Information” shall mean the information which identifies a User
i.e., first and last name, identification number, email address, age, gender,
location, photograph and/or phone number provided at the time of registration
or any time thereafter on the Platform.
We request you to not provide PROSHNO UTTOR with any Personal Information unless
specifically requested by us. In the event you share with PROSHNO
UTTOR any Personal Information
without us having specifically requested for the same, then we bear no
liability in respect of such Personal Information provided by you.
D. Information We Collect
We only collect information about you if we have a reason to do so — for
example, to provide our Services on the Platform, to communicate with you, or
to make our Services better.
We collect this information from the following sources:
Information we collect from You:
1. Basic account information: In order to
access certain features of the Platform, you will need to create an account and
register with us. We ask for basic information which may include your name, an
email address, state of residence, and password, along with a username and
phone/mobile number.
2. Information you choose to provide: When
you complete your profile within the Platform, you may choose to provide your
profile photo, name of your current educational institution and current grade.
We explicitly ask for your device camera permission if and when you want to
update your profile picture. This is not mandatory. This information is not
visible to anyone on or off the Platform.
3. Information when you communicate with
us: When you write to us with a question or to ask for help, we will keep that
correspondence, and the email address, for future reference; this may also
include any phone/ mobile numbers if you have provided us the same as part of
your communication either in writing (emails included), over a phone call or
otherwise. When you browse pages on our Platform, we will track that for
statistical purposes which may be to improve the Platform and the Services. You
may also provide us your Personal Information or other information when you
respond to surveys, enter any form of contests, tests, events, competitions,
webinars, etc., hosted by
PROSHNO UTTOR, either on the Platform or otherwise,
or when you otherwise communicate with us via form, e-form, email, phone, or
otherwise, we store a copy of our communications (including any call recordings
or emails, if any, as permitted by applicable law). When you use our paid doubt
solving feature, we explicitly ask for your device camera permission so that
you can share any associated image with us.
4. Information related to location: You
may also choose to provide location related information, including but not
limited to access to GPS, which will enable us, with your consent, to offer
customized offerings for specific services where location data is relevant
and/or applicable such as informing you whether services on the Platform that
you have expressed interest in may be availed of at or near your location.
Information we collect automatically:
1. Device and Log information: When you
access our Platform, we collect information that web browsers, mobile devices,
and servers typically make available, including the browser type, IP address,
unique device identifiers, language preference, referring site, the date and
time of access, operating system, and mobile network information. We collect
log information when you use our Platform — for example, when you create or
make changes to your account information on the Platform.
2. Usage information: We collect
information about your usage of our Platform. We also collect information about
what happens when you use our Platform (e.g., page views, support document
searches, features enabled for your account, interactions with other parts of
our Services) along with information about your Supported Device (e.g., screen
size, name of cellular network, and mobile device manufacturer). We use this
information to provide our Platform to you, get insights on how people use our
Platform so that we can make our Platform better, and understand and make
predictions about User retention.
3. Location information: We may determine
the approximate location of your Supported Device from your Internet Protocol
(IP) address. We may collect and use this information to calculate how many
people visit from certain geographic regions or to improve our Platform
Services.
4. Information from cookies & other
technologies: We may collect information about you through the use of cookies
and other similar technologies. A cookie is a string of information that a
website stores on a visitor’s computer, and that the visitor’s browser provides
to the website each time the visitor returns.
Information we collect from other sources:
We might receive and collect information about you from other sources in
the course of their services to us or from publicly available sources, as
permitted by law, which we may combine with other information we receive from
or about you. For example, we may receive information about you from a social
media site or a Google service if you connect to the Services through that site
or if you use the Google sign-in.
E. Basis of Collection and Processing of Your Personal Information
Basis for collection:
We collect and process your Personal Information based on the following
legal parameters depending upon the nature of Personal
Information and the
purposes for which it is processed:
1. Consent: We rely on your consent to
process your Personal Information in certain situations. If we require your
consent to collect and process certain Personal Information, as per the
requirements under the applicable Data Protection Laws, your consent is sought
at the time of collection of your Personal Information and such processing will
be performed where consent is secured.
2. Compliance with a legal obligation:
Your Personal Information may be processed by us, to the extent that such
processing is necessary to comply with a legal obligation.
Processing of your Personal Information:
We may process your Personal Information in connection with any of the
purposes and uses set out in this Policy on one or more of the following legal
grounds:
1. Because it is necessary to perform the
Services you have requested or to comply with your instructions or other
contractual obligations between you and us;
2. To comply with our legal obligations as
well as to keep records of our compliance processes;
3. Because our legitimate interests, or
those of a third-party recipient of your Personal Information, make the
processing necessary, provided those interests are not overridden by your
interests or fundamental rights and freedoms;
4. Because you have chosen to publish or
display your Personal Information on a public area of the Platform, such as a comment
area;
5. Because it is necessary to protect your
vital interests;
6. Because it is necessary in the public
interest; or
7. Because you have expressly given us
your consent to process your Personal Information in a particular manner.
We do not use Personal Information for making any automated decisions
affecting or creating profiles other than what is described in this Policy.
Where the processing of your Personal Information is based on your
consent, you have the right to withdraw your consent at any point in time in
accordance with
this Policy. Please note that should the withdrawal of consent
result in us not being able to continue offering our Services to you, we
reserve the right to withdraw or
cease from offering our Services to you upon
your consent withdrawal. You may withdraw consent by contacting us with a
written request to the contact details
provided in the ‘Grievances’ section
below. Upon receipt of your request to withdraw your consent, the consequences
of withdrawal may be communicated to you.
Upon your agreement to the same, your
request for withdrawal will be processed.
F. How we Use and Share the Information Collected
We use/process your information in the following manner:
1. To provide Services on our Platform: We
use your information as collected by us to allow you to access the Platform and
the Services offered therein, including without limitation to set-up and
maintain your account, provide customer service, fulfill purchases through the
Platform, verify User information and to resolve any glitches with our
Platform. The legal basis for this processing is consent or, where applicable,
our legitimate interests in the proper administration of our Platform, and/or
the performance of a contract between you and us.
2. To improve our Platform and maintain
safety: We use your information to improve and customize the Platform and
Services offered by us, including providing automatic updates to newer versions
of our Platform and creating new features based on the Platform usage analysis.
Further, we also use your information to prevent, detect, investigate, and take
measures against criminal activity, fraud, misuse of or damage to our Platform
or network, and other threats and violations to PROSHNO
UTTOR’s or a third party's
rights and property, or the safety of PROSHNO UTTOR, its users, or others. The legal basis
for this processing is consent or, where applicable, our legitimate interests
in the proper administration of our Platform, and/or the performance of a
contract between you and us.
3. To market our Platform and communicate
with You: We will use your information to develop a more targeted marketing of
our Platform, to communicate with you about our offers, new products, services
or even receive your feedback on the Platform. The legal basis for this
processing is consent or, where applicable, our legitimate interests in the
proper administration of our Platform, and/or the performance of a contract
between you and us.
4. To establish, exercise, or defend legal
claims: We may process any Personal Information identified in this Policy when
necessary for establishing, exercising, or defending legal claims, whether in
court, administrative, or other proceedings. The legal basis for this processing
is our legitimate interest in the protection and assertion of our legal rights,
your legal rights, and the legal rights of others.
5. To manage risk and obtain professional
advice:We may process any of the Personal Information identified in this Policy
to manage risk or obtain professional advice. The legal basis for this
processing is our legitimate interest in the proper protection of our business
and Platform
6. Consent:We may otherwise use your
information with your consent or at your direction.
7. To Better Understand Our Users:We may
use information we gather to determine which areas of the Services are most
frequently visited to understand how to enhance the Services.
We share the information collected as per terms of this Policy only in the
manner specified hereinbelow. We do not sell or otherwise disclose Personal
Information
we collect about you for monetary or other valuable consideration.
Further, only authorized representatives of
PROSHNO
UTTOR and on a need-to-know
basis use
any information received from you and as consented by you. In the
event of any identified unauthorized use or disclosure of information or upon
your complaint as
stated under the ‘Grievances’ section below, we will
investigate any such complaint and take the appropriate action as per the
applicable Data Protection Laws.
1. Third-party vendors/service providers
including integrated services on the Platform: We may share information about
you with third-party vendors or service providers (including consultants,
payment processors, and other service providers and integrated services) who
need the information to provide their support services to us or you, or to
provide their services to you on our behalf either directly or through the
Platform. These services may include providing customer support, performing
business and sales analysis, supporting our website functionality, facilitating
payment processing, and supporting contests, surveys, and other features
offered on our Platform. Such third-party vendors are not allowed to use the information
for any purpose other than what it was provided for, and they are required to
process and use the information in accordance with this Privacy Policy.
2. Legal Disclosures: We may disclose
information about you in response to a court order, or other governmental
request. Without limitation to the foregoing, we reserve the right to disclose
such information where we believe in good faith that such disclosure is
necessary to:
·
comply with applicable
laws, regulations, court orders, government and law enforcement agencies’
requests;
·
protect and defend PROSHNO
UTTOR’s or a third party's
rights and property, or the safety of PROSHNO UTTOR, our users, our employees, or others;
or
·
prevent, detect,
investigate and take measures against criminal activity, fraud and misuse or
unauthorized use of our Platform and/or to enforce our Terms and Conditions or
other agreements or policies.
3. To the extent permitted by law, we will
attempt to give you prior notice before disclosing your information in response
to such a request.
4. Business transfers:In the event PROSHNO
UTTOR
undergoes any merger,
acquisition, or sale of company assets, in part or in full, with another
company, or in the unlikely event that
PROSHNO
UTTOR goes out of business or
enters bankruptcy, user information would likely be one of the assets that is
transferred or acquired by a third party. If any of these events were to
happen, this Privacy Policy would continue to apply to your information and the
party receiving your information may continue to use your information, but only
consistent with this Privacy Policy.
5. Advertising and Analytics Partners:We
may share usage data with third-party advertisers, advertisement networks, and
analytics providers through cookies and other similar technologies.
6. With Your Consent:We may share and
disclose information with your consent or at your direction.
Your information may be shared for reasons not described in this Policy,
however, we will seek your consent before we do the same or share information
upon your
direction.
G. Duration for which your Information is Stored
Mostly, when you delete any of the information provided by you or when you
delete your account, on the Platform, the same will be deleted from our servers
too.
However, in certain cases, we will retain your information for as long as
it is required for us to retain for the purposes stated hereinabove, including
for the
purpose of complying with legal obligation or business compliances.
Further, please note that we may not be able to delete all communications
or photos, files, or other documents publicly made available by you on the
Platform (for
example: comments, feedback, etc.), however, we shall anonymize
your Personal Information in such a way that you can no longer be identified as
an individual
in association with such information made available by you on the
Platform. We will never disclose aggregated or de-identified information in a
manner that could
identify you as an individual.
Note: If you wish to exercise any of your rights (as specified in ‘Your
Rights’ section below) to access, modify and delete any or all information
stored about you,
then you may do so by using the options provided within the
Platform. You can always write to us proshno@proshnouttor.com.bd for any
clarifications needed.
H. Your Choices
Limit the information You provide: You always have an option to choose the
information you provide to us, including the option to update or
delete your
information. However, please note that lack of certain information may not
allow you the access to the Platform or any of its features, in part or in
full.
Limit the communications You receive from us: Further, you will also have
the option to choose what kind of communication you would like to receive from
us
and whether you would like to receive such communication at all or not.
However, there may be certain communications that are required for legal or
security
purposes, including changes to various legal agreements, that you may not
be able to limit.
Reject Cookies and other similar technologies: You may reject or remove
cookies from your web browser; you will always have the option to change the
default
settings on your web browser if the same is set to ‘accept cookies’.
However, please note that some Services offered on the Platform may not
function or be
available to you, when the cookies are rejected, removed, or
disabled.
I. Information Security
We work to protect the security of your information during transmission by
using Transport Layer Security (TLS) or Secure Sockets Layer (SSL) software
(depending on your browser/Supported Device), which encrypts information you
input in addition to maintaining security of your information as required under
applicable laws.
We maintain electronic, and procedural safeguards in connection with the
collection, storage, and disclosure of Personal Information (including
Sensitive Personal
Information). Our security procedures mean that we may
occasionally request proof of identity before we disclose Personal Information
to you that belongs to you.However, no form or method of data storage or transmission system is fully
secure, and we cannot guarantee that security provided by such system(s) is
absolute and that your information will not be accessed, disclosed, or
destroyed in the event of a breach of any of our security measures.
It is important for you to protect your account against unauthorized
access to or use of your password and to your computer and if you have any
reason to believe
that your password has become known to anyone else, or if the
password is being, or is likely to be, used in an unauthorized manner, you must
immediately
change your password or inform us, so that we are able to help you
stop or prevent such unauthorized access. Be sure to sign off when you finish
using a shared computer.
J. Promotional Communications
You will always have the option to opt out of receiving some or all of our
promotional communications by using the unsubscribe link in any email
communications sent to you or by emailing proshno@proshnouttor.com.bd.
If you opt out of promotional communications, we may still send you
transactional communications, such as service announcements, administrative and
legal notices, and information about your account, without offering you the
opportunity to opt out of these communications. If you no longer wish to use
our Platform or receive any communications from us (except for those that are
legally required), then you may delete your account by using the option enabled
within the Platform or by writing to us at proshno@proshnouttor.com.bd.
Advertisers or ad companies working on their behalf sometimes use
technology to serve the ads that appear on our sites directly to Your browser.
They automatically receive Your IP address when this happens. They may also use
cookies to measure the effectiveness of their ads and to personalize ad
content. We do not have access to or control over cookies or other features
that advertisers and third-party sites may use, and the information practices
of these advertisers and third-party websites are not covered by our Policy.
Please contact them directly for more information about their privacy
practices.
Please note that opting out of promotional email communications only
affects future communications from us. If we have already provided your
information to a third party (as stated in this Policy) before you changed your
preferences or updated your information, you may have to change your
preferences directly with that third party.
We do not sell your Personal Information to third parties, and we do not
use your name or name of your company in marketing statements without your
consent.
K. Interest-Based Ads
On unaffiliated sites, PROSHNO UTTOR may display interest-based
advertising using information you make available to us when you interact with
our Platform and Services. Interest-based ads, also sometimes referred to as
personalised or targeted ads, are displayed to you based on information from
activities such as registering with our Platform, visiting sites that contain PROSHNO
UTTOR content or ads. We do not provide any Personal Information to advertisers
or to third party sites that display our interest-based ads. However,
advertisers and other third-parties (including the ad networks, ad-serving
companies, and other service providers they may use) may assume that users who
interact with or click on a personalised ad or content are part of the group
that the ad or content is directed towards. Also, some third-parties may
provide us information about you (such as the sites where you have been shown
ads or demographic information) from offline and online sources that we may use
to provide you more relevant and useful advertising.
Advertisers or ad companies working on their behalf sometimes use
technology to serve the ads that appear on our sites directly to your browser.
They automatically receive your IP address when this happens. They may also use
cookies to measure the effectiveness of their ads and to personalise ad
content. We do not have access to or control over cookies or other features
that advertisers and third-party sites may use, and the information practices
of these advertisers and third-party websites are not covered by our Policy.
Please contact them directly for more information about their privacy
practices.
L. Modification to Privacy Policy
Our business changes constantly and our Policy may change from time to
time. We may, at our discretion (unless required by applicable laws to
mandatorily do so), email periodic reminders of our notices and conditions,
unless you have instructed us not to, but we encourage you to check our
Platform frequently to see the recent changes. Unless stated otherwise, our
current Policy applies to all information that we have about you and your
account. We stand behind the promises we make, however, and will not materially
change our policies and practices making them less protective of customer
information collected in the past without your consent.
M. Privacy Grievances
If you have any questions about this Policy, wish to exercise your rights,
have concerns about privacy of your data or any privacy related grievances in
respect of the Platform, then please register your complaint with a thorough
description via email to proshno@proshnouttor.com.bd or call our hotline at +8801617226807.